Cabagnot v. Commission on Elections
REITERATIONFacts
The Antecedents: During the May 8, 1995 elections, Corazon L. Cabagnot and Florencio T. Miraflores were candidates for the governorship of Aklan. Miraflores was proclaimed winner. Cabagnot filed an election protest and a petition for disqualification against Miraflores. Subsequently, she filed a "Petition Ad Cautelam" (EPC No. 95-25) seeking to impugn Miraflores' election and proclamation. Procedural History: On January 23, 1996, the Comelec First Division issued an Order designating Kalibo, Aklan as the venue for the revision of ballots. Cabagnot moved for reconsideration, arguing for Manila as a neutral place to insulate the revision from partisan activities and offering to shoulder expenses for a Manila venue. On March 28, 1996, the Comelec En Banc, voting 4 to 1, denied the motion, stating that the designation of venue is within its discretion and that the integrity of the proceedings is the only material consideration. The Petition: Cabagnot filed a petition for certiorari with the Supreme Court, challenging the Comelec's Order and Resolution, alleging grave abuse of discretion in denying her motion to maintain the venue in Manila, where the Comelec and its Clerk of Court are located, pursuant to Comelec Rule 20, Sections 6 and 9.
Issue(s)
Whether the Commission on Elections committed grave abuse of discretion in changing the venue for the revision of ballots from Manila to Kalibo, Aklan, thereby violating its own rules and established practice. Whether the Comelec's denial of the motion for reconsideration, which sought to maintain the venue in Manila, was justified, considering the potential impact on public trust and the consistency of Comelec's decisions.
Ruling
The petition is GRANTED. The assailed Order and Resolution are declared NULL and VOID. The respondent Commission is DIRECTED to transfer the contested ballots to Manila consistent with its own rules and precedents in similar cases cited above; to forthwith obtain adequate storage space and install appropriate security measures therein; and to proceed with judicious dispatch in the cases before it involving herein petitioner and private respondent to the end that substantial justice is dispensed.
Ratio Decidendi
On the issue of grave abuse of discretion in changing the venue of the revision of ballots: The Supreme Court found merit in the petition, ruling that the Commission on Elections (Comelec) committed grave abuse of discretion. The Court noted that the Comelec had a consistent practice of granting requests to hold ballot revisions in Manila, citing previous cases such as Guingona, Antonio, Gustilo, Trinidad, and Binay. In these analogous cases, the Supreme Court had consistently upheld the Comelec's resolutions setting the revision venue at its head office in Manila. The Court found the Comelec's reversal of its doctrine on the "puerile argument of lack of space" to be a violation of its own rules and established practice. The Court emphasized that while the Comelec possesses ample constitutional power to exercise exclusive original jurisdiction over election contests, it must exercise such power prudently and not whimsically or capriciously. On the issue of the justification for denying the motion for reconsideration: The inconsistent actions of the Comelec, granting similar requests in other cases while denying the petitioner's plea without sufficient justification, tended to denigrate public trust in its objectivity and dependability. The Court reiterated that when the Comelec exceeds or abuses its jurisdiction gravely, it is subject to review and reversal by the Supreme Court. The Court also pointed out that the "lack of space" excuse was raised belatedly in the Comelec's Comment, after the Solicitor General declined to represent it, further weakening its justification. The Court concluded that such "arrogance of power" constituted abuse, especially when it departed from its own rules and usual practice without adequate justification. The Court directed the Comelec to transfer the ballots to Manila, obtain adequate storage, and proceed with dispatch.
Main Doctrine
The Commission on Elections (Comelec) committed grave abuse of discretion in changing the venue for the revision of ballots from Manila to Kalibo, Aklan, deviating from its own rules and established precedents without sufficient justification, thereby undermining public trust in its objectivity.